Introduction

This information notice aims at explaining to all users of AirVantage (either on https://na.airvantage.net or https://eu.airvantage.net), Source, Forum, Octave and Gerrit websites the purposes and features of the use of their personal data (the “Information Notice”).

As soon as a user:

• registers and creates (the “Users”) an account on Forum and Source websites;
• sends a request (the “Prospect“) in connection with the Sierra Wireless Services; and/or
• subscribes (the “Client“) to the Sierra Wireless services either by registering an AirVantage and or Octave trial account or by having a new user account created by AirVantage’s and/or Octave’s administrator, irrespective of the Sierra Wireless services to which the Client has subscribed (the “Services“) with any of the Sierra Wireless group entities;

Sierra Wireless processes, on its own behalf, Prospects and Clients personal data and acts a data controller in this respect.

1. The data controller of your personal data and its data protection officer

As part of its activities, Sierra Wireless S.A. and the Sierra Wireless group entities (“Sierra Wireless”, “Us” or “We“) process only relevant and strictly necessary personal data. Sierra Wireless takes care of the User’s, Prospect’s and Client’s personal data it processes in order to provide access to its websites, answer the User’s, Prospect’s and Client’s requests and/or inquiries, and supply its Services. In this respect, Sierra Wireless processes your personal data and facilitates the exercise of your rights in compliance with the General Data Protection Regulation No. 2016/679 (“GDPR“). If you have any concern or question on the processing of your personal data, you may contact us at privacy@sierrawireless.com.

In order to better address its personal data protection duties, Sierra Wireless has designated a data protection officer (the “DPO“). If you wish to contact the DPO in relation to the processing of your personal data, please contact him by sending an e-mail at dataprotectionofficer@sierrawireless.com.

2. Client’s and Prospect’s personal data we collect

Sierra Wireless collects personal data directly from the Users, the Prospects and/or the Clients, and their activities in relation to the use of the Sierra Wireless websites and Services. Sierra Wireless collects personal data from the Prospect’s creation of an account on Source, Forum and Octave websites and/or from the Prospect’s requests sent to Sierra Wireless in connection with the Services and related products.

Sierra Wireless collects personal data from the Clients for:

• the creation of the account (email address, firstname, lastname, country);
• the subscription to the Services, notably the subscription to the Connectivity Service;
• the use of the multi factor authentication (“MFA”) (e.g. phone number);
• the service billing (postal address, card number).

3. Use of the Client’s personal data

4. Personal data applicable retention period

4.1. Regarding the Users and the Prospects, for a period of time not exceeding the greater of:

• duration of the account created by the User on the Forum and the Source websites;
• three years as from the data collection or the last contact initiated by the Prospect;
• duration of the advertising campaigns carried by Sierra Wireless or the specific consent provided to Sierra Wireless for such advertising activities;
• duration of the consent provided for the promotion of products and services different from those for which the prospect contacted Sierra Wireless.

4.2. Regarding the Clients, for a period of time not exceeding the greater of:

• Two months as from the term of the free trial account (Device Management free trial accounts are automatically deactivated after 6 months), where the Client did not further subscribe to a Service;
• duration of the user account provided upon subscription of a Service;
• duration of the agreement entered into between the Client and Sierra Wireless;
• duration of the advertising campaigns carried by Sierra Wireless or the specific consent provided to Sierra Wireless for such advertising activities;
• duration of the consent provided to Sierra Wireless to promote products and services different from those for which the Client has sent a request to Sierra Wireless and/or has entered into an agreement with Sierra Wireless;
• the applicable duration of the statute of limitations.

6. Personal Data transfers

Transfers to the recipients in Article 5 involve a transfer of personal data outside the European Union to other Sierra Wireless entities.

For this purpose, only Sierra Wireless’ authorized personnel and/or processors can access to your data upon our instructions only. In the case the data transfer is carried to a destination country outside the European Union that does not ensure an adequate level of protection, Sierra Wireless has implemented appropriate safeguards to protect such data. Information and a copy of such appropriate safeguards may be obtained upon request at privacy@sierrawireless.com.

7. User’s, Prospect’s and Client’s rights over their personal data

Users, Prospects and Clients are hereby informed that their personal data may be used for advertising purposes that require the implementation of profiling activities.

7.1. Clients and Prospects rights

Users, Prospects and Clients are informed that they may access, rectify, request the erasure of their personal data, obtain the restriction of the processing and/or to object the processing of their personal data, on grounds relating to their particular situation, and use their right to data portability if applicable. Users, Prospects and Clients are hereby informed that where the processing is based on consent, they may withdraw their consent at any time.

In order to exercise any of the rights mentioned before, please follow the instructions provided in Section 7.3 or, if you face any difficulties, please contact Us at privacy@sierrawireless.com.

Users, Prospects and Clients may also lodge a complaint with the relevant supervisory authority.

7.2. Users’, Prospects’ and Clients’ rights in France

With regard to Sierra Wireless entities located in France, pursuant to French applicable law, in addition to section 7.1, Users, Prospects and Clients may also contact Sierra Wireless French entities to define the instructions for the processing of their personal data after their death. In order to exercise this right, please contact Us at privacy@sierrawireless.com.

7.3. Manage your Information

Where applicable, Users, Prospects and Clients can access and change their personal data, withdraw their consent at https://login.sierrawireless.io/user/details at any time.

Users, Prospects and Clients may:

8. Changes to this Information Notice

This Information Notice may be modified by Sierra Wireless from time to time so as to keep it updated and accurate. In the event of a change of this Information Notice, the updated version of the Information Notice will be displayed to the Users, Prospects and Clients upon your access to their account and/or will be sent to them by email at the email address they provided to Sierra Wireless with for further communication.